Government is aware that there may be labelling problems due to supply pressures being experienced at this current time. Over a number of weeks, they have been working to provide guidance in this area and in the last week have given a steer to enforcement authorities on a pragmatic approach to take. We have been assured that some sort of guidance to industry will follow in the coming days but in the meantime please find below a top line summary of the communications to Enforcement Authorities.
Please note: If you are looking for any specific business continuity advice then please do not hesitate to contact your local trading standards and environmental health officers – they will be more than happy to help and of course will treat all discussions in confidence.
- As a result of the COVID-19 pandemic, and in response to abrupt and potentially disruptive changes in food supply chains, there may be exceptional circumstances when you may wish for a temporary flexibility on certain rules on food labelling. So long as safety and authenticity are not compromised, your Primary Authority or local authority may consider agreeing to those needs to ensure the ongoing supply of food into the market is not delayed.
- Businesses may encounter difficulties in making labelling changes in a very short time for temporary situations with potentially long lead times and high cost. It is appropriate to strike a balance between reasonable and pragmatic requirements for businesses and managing risks to consumers, whilst ensuring the ongoing provision of food throughout the supply chain in these turbulent times.
- Of course, the overriding concern is to protect consumer safety, and additionally that consumers are not misled. The Primary Authority is willing to work with food businesses on an individual basis to establish and agree the precise nature of any temporary deviation from labelling requirements and its duration.
- To ensure full traceability and transparency, agreed changes are to be notified to the FSA. This will allow a central register to be kept of any changes to food composition or labelling which may impact consumers.
- This approach is recognised by the Food Standards Agency and Defra, and will be reviewed at the end of May 2020